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Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

by | Jan 28, 2020

The CFE ECJ Task Force has prepared an Opinion Statement on the General Court decisions of 24 September 2019, in Cases C-760/15 & T-636/16, The Netherlands v. Commission (Starbucks), and Cases T-755/15 and T-759/15, Luxembourg v. Commission (Fiat Finance and...
Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

Opinion Statement ECJ-TF 4/2019 on the CJEU decision in Case C-135/17, X-GmbH, concerning the application of the German CFC legislation in relation to third countries

by | Dec 12, 2019

The CFE ECJ Task Force has prepared an Opinion Statement on Case C-135/17, X GmbH, in which the Court of Justice of the EU (Grand Chamber) (ECJ) delivered its judgment on 26 February 2019. In general terms, the ECJ largely followed the opinion given by Advocate...
Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

Opinion Statement ECJ-TF 3/2019 on the CJEU decision of 22 November 2018 in Case C-575/17, Sofina, on withholding taxes, losses and territoriality

by | Oct 11, 2019

The CFE ECJ Task Force has prepared an Opinion Statement on the Sofina-case, in which the Fifth Chamber of the Court of Justice of the EU delivered its decision on 22 November 2018. In the decision, the Court held that the imposition of French dividend withholding tax...
Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

Opinion Statement ECJ-TF 2/2019 on the CJEU decisions concerning the “Beneficial Ownership”

by | Jun 24, 2019

CFE Tax Advisers Europe acknowledges that the “Danish beneficial ownership cases” address a number of important and timely issues, especially with regard to the concept of abuse in EU law. Those include (1) the expansion of the general anti-abuse principle enshrined...
Opinion Statement ECJ-TF 1/2020 on the Starbucks and Fiat State Aid Decisions

Opinion Statement ECJ-TF 3/2018 on the Case C-650/16, Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment

by | Nov 15, 2018

CFE Tax Advisers Europe has published an Opinion Statement on the Court of Justice decision of 12 June 2018, in Case C-650/16 Bevola, concerning the utilisation of “definitive losses” attributable to a foreign permanent establishment and the viability of the Marks...
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